Compliance Blog - R.J. Hedges & Associates

Offering immunizations in your pharmacy is a wonderful thing. It is a great way to generate more traffic into your pharmacy, thus increasing OTC, retail and prescription sales and it is a great service to offer your patients.

But when getting ready to set up your immunization program, there can be a lot of questions you have. Below is a list of some of our most commonly asked questions.

Can a nurse do flu shots if she is a license LVN or RN?

A nurse may provide immunizations when operating with a valid state license and operating within the scope of practice.

Can a Certified Technician get trained to give immunizations?

I am not aware of any state or territory in the U.S. that will permit Pharmacy Technician’s to immunize

Do I need to buy all new stand alone refrigerators?

You will only need to buy a new refrigerator if you are using a dormitory style refrigerator.

Must I have a medical grade refrigerator?

No. Only required for hospitals

I’m looking for insurance carrier who will include flu shots.

Pharmacist Mutual is the only insurance company that I’m aware of that provides full coverage to the pharmacy, pharmacists and physicians signing Standing Orders

Can you negotiate a cash price for flu shots with a company factory organization etc that is lower than what you charge Medicare?

Absolutely! When you negotiate a group fee for immunizations, this is outside the U&C

What's the best way to expand into Travel Vaccines?

Market to schools, universities, churches and faith based organizations, companies, especially those who travel internationally

What about shots in an offsite location i.e. employers site or even a second store that is not registered as a Medicare biller with the shots billed thru the original store? Can you do that or how do that?

Immunizations are not limited to the pharmacy, you may go to any place within the authority of your pharmacist/Immunizing Pharmacist license.

For independent pharmacy, what options are available for a protocol doctor or how do I find a medical professional to protocol?

Start with your neighborhood physician. They may offer flu, but not the other vaccines. Their reimbursements have been cut

Are there designated physicians available in each state for being a protocol doctor?

Unfortunately no. The pharmacy must seek out their own physician as required by state law

Does your pharmacy need a surety bond for Medicare Part B when submitting vaccination claims for these patients?

No. Surety bond is only required, at this time, for Medicare NSC PTAN’s

There is no formal requirement, but the rule of thumb is, enough room that if a patient faints, they don’t hit a wall.

Is there a resource that lists what vaccines are able to be administered and billed by a pharmacist versus which vaccines are not?

This varies from state to state.

For states that require pharmacist administered immunization data submitted to statewide registry; what is the processes (documentation) the pharmacy should use if a patient opts-out of having their data sent to the registry?

This is a difficult question to answer. You need to compare the requirements of the state registry law against the new HIPAA statutes. The most stringent rule must be followed.

What if your sponsoring doctor does not want to be inundated with faxes of vaccine records for patients that he is not the PCP for?

Physician may receive the records in an electronic format. Emailing the records must be encrypted by the sending and receiving parties. HIPAA statute

We are a "Yellow Fever Approved" Clinic but why the strict requirements?

You are working with a live virus that has a short life span

Merck's multi dose vial of Pneumovax23 package insert states discard after expiration date is an open vial good for the entire shelf life or must we discard it 28 days after opening?

You must follow the manufacturer’s recommendations and instructions.

Do you a question about offering immunizations? Leave us a comment and we will do our best to answer it!

Jenny is a Board Certified DME Specialist and for the last 8 years has assisted independent pharmacies, home health care facilities, medical supply companies, physicians and small healthcare practices in choosing the best comprehensive customized healthcare compliance and consulting services they require.